1. 关于支柱2下GloBE规则的第三批行政指南: https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-december-2023.pdfwww.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-december-2023.pdf 2. 更新支柱1下关于金额A多边公...
On 17 June 2024, theOECD/G20 Inclusive Framework on BEPS(“OECD inclusive framework”) published further administrativeguidanceon the implementation of the Pillar Two global minimum tax rules ("Pillar Two"), together with details of the processes for determining that jurisdictions' local implementation...
Administrative guidance was released in February 2023 on allocating blended CFC taxes (such as US GILTI (global intangible low-taxed income)) to group entities for the purposes of the Pillar Two calculations using a formulaic approach based on “blended CFC allocation keys.” Further guidance has ...
The European Commission is expected to publish a proposal for a Pillar 2 implementing EU Directive on December 22, 2021. The OECD is set to provide more guidance in the form of a Commentary and a Pillar 2 implementation framework during the course of 2022 and, moreover, publish a model ...
Summary of OECD Pillar 2 Guidance The documents released on December 20, 2022 are: Guidance on Safe Harbors and Penalty Relief A public consultation document on the GloBE Information Return and A public consultation document on Tax Certainty for the GloB...
(OECD) released the following guidance and public consultation documents1 on Pillar Two of Base Erosion and Profit Shifting (BEPS) 2.0: (1) guidance on safe harbours and penalty relief (not subject to public consultation); (2) public consultation document on the Global Anti-Base Erosion (...
On 17 June, the OECD/G20 Inclusive Framework released a fourth tranche of Administrative Guidance on the Pillar Two GloBE Rules. The topics covered in the Administrative Guidance are deferred tax liability recapture, divergence between GloBE and accounti
work on the implementation of the two-pillar plan is well under way. As part ofthis next phase...
Tax Policy Alert OECD releases Administrative Guidance on the Pillar Two Global Minimum Tax Rules 7 February 2023 In brief The OECD released Administrative Guidance ('guidance') on the Pillar Two Global Anti-Base Erosion Rules (GloBE Rules) on 2 February. The guidance was approved by the OECD/...
Safe Harbours The Commentary provides no substantive discussion of what Pillar Two safe harbours might be – despite the importance of this to business. It does, however, although slightly less helpfully, include some administrative guidance on how any safe harbour rules eventually adopted might ...